A consolidated view of the regulatory timelines for uncleared margin regulations

Global regulators are moving towards placing margin requirements on un-cleared OTC business. Knowing when you need to comply keeps changing, so below is my best effort at setting out the latest situation.  Recent updates from Singapore and Australia have blurred the picture in Asia with Hong Kong expected to follow suit.

• Singapore MAS: http://www.mas.gov.sg/Regulations-and-Financial-Stability/Regulations-Guidance-and-Licensing/Securities-Futures-and-Funds-Management/Circulars/2016/Circular-on-Margin-Requirements-for-NonCentrally-Cleared-Derivatives.aspx
• Australian PRA: http://www.apra.gov.au/CrossIndustry/Pages/Consultation-margining-risk-mitigation-February-2016.aspx
• Good updates from DRS LLP: http://www.drsllp.com/blog/non-cleared-derivatives/singapore-australia-join-margin-rule-delay-bandwagon/

Summary

• US & Japan: No change to the original timeline, so VM & IM starting very soon
• Europe sticking to the original timetable, but with the start of VM and IM timed to be one month after they finalise the regulations (so the arrows below are not fixed)
• Singapore & Australia: No published timetable – references to other 'major regulators', implies they may wait for Europe
• Hong Kong: No change now, but the HKMA are mentioned in the announcements from Singapore and Australia and may also 'blur' their timeline